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Renters’ Rights Bill and Student Accommodation: The Final Stretch?

Posted by:

Date:

24/09/2025

Read Time:

9 min read

The Renters’ Rights Bill had its first reading in the Commons on 11 September 2024—barely ten weeks after Labour took office—signalling a hard push to abolish Section 21 “no-fault” evictions and overhaul the private rented sector (PRS). The Bill substantially builds on Michael Gove’s Renters (Reform) Bill, which fell at the end of the previous Parliament, and it keeps a laser focus on delivering a one-stage conversion to the new tenancy system. Ministers have repeatedly said the sector has debated long enough: the direction of travel is set, and refinements (not wholesale rewrites) now dominate.

Where does that leave students and the people who house them? In short: students are still a “special case”, but in a much more structured and explicit way. Purpose-built student accommodation (PBSA) is being carved out of the assured tenancy regime, while off-street student housing remains inside it—albeit with a tailored ground for landlords to regain possession in line with the academic year. And crucially, tenants—including students in off-street houses—will gain the right to give two months’ notice at any time, ending their tenancy.

This article sets out the key moving parts for 2025, what changed in the House of Lords over the summer, what’s likely next procedurally, and how students, universities, PBSA providers, and off-street landlords should prepare.

Where the Bill is now (autumn 2025)

The Bill cleared the Commons in January 2025, completed Lords stages on 21 July 2025 with a suite of amendments, and returns to the Commons on 8 September 2025 for consideration of those Lords changes (the familiar “ping-pong” phase). That timetable means Royal Assent is widely expected in autumn 2025, with commencement likely in early 2026 once secondary legislation and guidance are ready. The Government still intends to switch the entire PRS over in one stage on a single “conversion day.”

The architecture: two tracks for student housing

1) PBSA: out of the assured tenancy regime (common-law contracts)

Government policy is to exempt private PBSA that comply with approved student housing Codes (Unipol/ANUK) from the new assured tenancy framework. This aligns PBSA with university-managed halls: contracts become common-law rather than assured, so fixed terms can continue, and repossession becomes a matter of contract and common law, not statutory grounds. Ministers will use powers outside the Bill (under the Housing Act 1988 / Housing Act 2004 codes framework) to effect this exemption in step with Code membership, avoiding a constantly updated list in secondary legislation.

What that means in practice:

Fixed terms remain standard in PBSA.
Some protections that attach to “assured” status (e.g., the statutory deposit scheme rules) don’t automatically apply to common-law tenancies unless the Government or Codes pull them back “into scope.” Code administrators are expected to close consumer-protection gaps (for example, by requiring deposit protection as a condition of Code membership).

2) Off-street student lets: inside the assured regime, with a tailored possession ground

Off-street student houses (traditionally HMOs) sit inside the new assured periodic system. To keep those homes available on an academic cycle, the Bill creates Ground 4A (mandatory) so landlords can recover possession for the next cohort of students:

Landlord must signpost at the start that they intend to rely on Ground 4A.
They must give four months’ notice, and it must take effect between 1 June and 30 September.
The next let must be to full-time students (or those reasonably expected to become full-time students).

Important summer 2025 update: The House of Lords expanded Ground 4A to one- and two-bed student lets, not just HMOs with three or more sharers. That change—if accepted by the Commons—addresses the risk that small student properties would otherwise drift into the general PRS and out of the academic cycle.

Tenants’ new right to give two months’ notice—any time

Perhaps the biggest behavioural change is that every assured periodic tenant can now leave on two months’ notice at any point. The earlier idea (in 2023/24 drafts) of “no notice in the first four months” has gone. For students in off-street houses, this creates:

Start-of-year exits (course changes; clearing outcomes). Many good landlords already negotiated surrenders in such cases; this formal right marginally increases exposure.
Mid-year moves (housemate friction / quality issues). Expect a more active mid-year market for backfilling rooms.
Early summer departures (May/June): potential voids and exposure to Council Tax if a house becomes empty (student exemption relies on occupation).

In joint tenancies, one housemate’s notice ends the whole tenancy unless the remaining occupiers and landlord agree a new one. The Lords also passed an amendment tightening how joint notices work (e.g., rules on shortening or withdrawing notices), aiming to reduce “accidental” termination chaos. Expect more admin, clearer house rules, and a premium on mediation.

Rents, pets, bidding, redress: the cross-sector rules students will feel

Monthly in advance only: No more termly billing in off-street assured tenancies. That breaks alignment with student loan drops and may drive more guarantor use or larger deposits to manage arrears risk.
Rent increases: One per 12 months; tenants can refer above-market rises to the First-tier Tribunal, which can raise or lower to market.
Pets: Stronger right to request; landlords can’t unreasonably refuse (the Lords removed a blanket pet-insurance requirement and explored a limited “pet deposit” concept).
End to rent bidding: Agents/landlords must advertise a price and cannot solicit/accept offers above it.
Ombudsman + PRS Database: A single, mandatory landlord ombudsman and a national database to drive transparency and give enforcers leverage; registration may be required to use certain grounds.
Decent Homes Standard: Extended to the PRS; in many licensed HMOs, existing standards already exceed the baseline.

Timing and transition: what to expect

Commons “ping-pong”: From 8 September 2025, MPs decide which Lords amendments to accept.
Royal Assent: Widely expected autumn 2025.
Commencement: Government intends a one-stage conversion in early 2026, with guidance and secondary legislation first. On “conversion day,” all ASTs convert to assured periodic, and all new tenancies use the new rules. Ministers have promised sufficient notice and a guidance campaign for landlords and tenants.

Practical implications by stakeholder

For off-street landlords and agents

Map your portfolio: If Ground 4A stays expanded, it will cover HMOs and 1–2-bed student lets. If the Commons narrows it, small units may be better placed in the general PRS. Build Plan A/Plan B around the ping-pong outcome.

Rewrite your tenancy packs:

Clear Ground 4A signposting (where applicable).

Monthly billing terms; rent-increase clause synced with tribunal timelines.

Joint tenancy protocol (what happens if one housemate serves notice).

Cash-flow stress tests: Model May–July voids and Council Tax on empties; price risk into weekly rents if necessary.

Leasing calendar: Consider June start dates to mitigate May/June exits.

Mid-year marketing engine: Keep a pipeline to backfill rooms quickly (intra-uni communities, accredited listings, SU partnerships).

For PBSA providers (Code members)

Lock in Code status to ensure assured-tenancy exemption lands on day one.

Refresh contracts as common-law fixed terms, with fair, transparent clauses (arrears triggers, loss of student status, conduct).

Decide on deposits: Even if statutory schemes don’t strictly apply, align to Code-level protection to maintain student confidence.

For universities and students’ unions

Budget comms: Students need to understand monthly rent and notice mechanics (e.g., “leaving in May” means serve notice in March).

Mid-year mobility: Set up room-swap boards and mediation services for house friction.

Non-September cohorts: January starters and some postgraduates don’t map neatly to the June–September Ground 4A window; work with local providers on tailored allocations.

For students

Know your notice: Two months, any time; in a joint tenancy, your notice can end it for everyone—coordinate early.
Budget monthly: No more termly rent in off-street assured lets; expect more frequent guarantor requests.
Expect higher admin mid-year but also more choice if others move.

Risks, trade-offs and likely market responses

Small student stock leakage: Without the Lords’ expansion of Ground 4A, one- and two-bed student homes would likely migrate to the general PRS, shrinking student supply. The Lords tried to fix this; the Commons’ decision is pivotal.
Rents drifting up: Landlords will price in void risk and admin load. Expect modest upward pressure, especially where supply is tight.
Winners and “collateral damage”: Longer-term professional renters may benefit from stability; some student and benefit-recipient segments may see tighter screening or reduced choice.
Overall supply: The broader PRS contraction appears to have stalled, but mix within the PRS could shift—for example, towards professionals or short-lets in some cities.

Five open questions to watch in “ping-pong”

Ground 4A scope: Will MPs accept the Lords’ expansion to cover 1–2-bed student lets, or revert to HMOs only? This single decision will shape student supply in many towns.

PBSA exemption mechanics: Implementation should be seamless with Code membership, but watch for any transitional hiccups.

Deposit protection for PBSA common-law tenancies: Will Ministers or Codes mandate it equivalently to assured tenancies?

Joint tenancy refinements: The Lords added tweaks on shortening/withdrawing notices; expect guidance to reduce accidental endings.

Go-live date & phasing: Still one-stage by policy, but commencement details will emerge via secondary legislation and guidance; early 2026 remains the working expectation.

Conclusion: buckle up for summer 2026

The big win for students in off-street homes is clear: freedom to leave on two months’ notice at any time, and stronger consumer tools across the PRS (ombudsman, database, decent homes, rent-bidding ban). But predictability for landlords is trimmed, and unless the Commons banks the Lords’ broader Ground 4A, some smaller student properties may migrate out of the student market, nudging rents up and choice down in certain areas. PBSA, by contrast, looks relatively steady: fixed-term common-law contracts continue, underpinned by Codes.

No one can model the exact behavioural shifts until the rules are final and guidance lands. But the contours are visible: a more flexible tenant landscape; a PRS that prices and manages new risks; and a student market that must get better at mid-year matching and clear budget comms. If Parliament sticks to the current trajectory, Royal Assent in autumn 2025 and a one-stage conversion in early 2026 will turn the page—ending Section 21 and launching student housing into a new legal era.

Sources and further reading

House of Commons Library – Renters’ Rights Bill 2024–25: Consideration of Lords amendments (2 September 2025). Confirms Lords’ expansion of Ground 4A to one- and two-bed student lets, PBSA exemption mechanics, and implementation approach.
GOV.UK – Guide to the Renters’ Rights Bill (16 January 2025). Sets out core reforms (abolition of Section 21, periodic tenancies, rent increases, PRS database, ombudsman).
HEPI – Renters’ Rights Bill and Student Accommodation: The Final Stretch? (9 October 2024) and subsequent analyses explaining the PBSA carve-out and the student market design.
Sector commentary (summer 2025): Overviews of student-specific possession grounds and PBSA positioning as the Bill moved through the Lords.

Note: The Bill is in “ping-pong” as of September 2025. Specifics (especially the final scope of Ground 4A) depend on Commons decisions on Lords amendments. Always check the enacted Act and commencement regulations before advising on live cases.

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